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May 19, 2021


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Jeremy Bearer-Friend

Thank you for the shout out Bridget and cheers to your amazing students for diving into this work! I believe the form is the result of a second term Obama Treasury reg, after Treasury had been dragging its feet for decades on complying with the Civil Rights Act of 1964. Under that Act, grantees of the federal government must show that they do not discriminate against beneficiaries, and in the late 70s DOJ required standardized collection of race data to prove that. But Treasury wasn't requiring VITA site grantees to collect the data until a few years ago. Here's the cite for the Treasury Reg requiring the collection and how they use the data. Regulation Regarding Nondiscrimination on the Basis of Race, Color, or National Origin in Programs or Activities Receiving Federal Financial Assistance, 81 Fed. Reg. 89,852 (Dec. 13, 2016) (to be codified at 31 C.F.R. pt. 22). The ironic thing about it is that we now have higher standards for reviewing the nondiscrimination conduct of Treasury grantees than we do for IRS and Treasury themselves. Something we need to change!

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